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ESTATE OF MacCROWE v. COMMISSIONER

Docket No. 50146.

14 T.C.M. 958 (1955)

T.C. Memo. 1955-238

Estate of Albert E. MacCrowe, Deceased, James C. L. Anderson, Administrator, de bonis non, with the will annexed, and Hazel B. MacCrowe (now Hazel B. Keen), Surviving Wife v. Commissioner.

United States Tax Court.

Filed August 26, 1955.

Attorney(s) appearing for the Case

D. Sylvan Friedman, Esq., for the petitioners. William Schwerdtfeger, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent has determined deficiencies in income tax and negligence penalties under section 293(a), I. R. C. of 1939, as follows:

  Year              Deficiency     Penalty

  1948 ...........  $95,503.26    $4,902.74
  1949 ...........   36,163.86     1,808.19

The first issue is whether respondent correctly determined decedent's gross receipts from his medical practice in...

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